Transcript Inventory Update Rule Amendments February 1999

Discussion of the 2006 Inventory
Update Reporting Data
December 12, 2006
Nhan Nguyen
U.S. EPA
1
Presentation Overview






What is IUR?
What data are collected?
Who is required to report?
Where can one find historical IUR information?
How will IUR data be used?
Your input/suggestions on uses of IUR data
2
The Inventory Update Reporting (IUR)
Rule collects information from
chemical manufacturers and importers
to update the TSCA Inventory of
Chemical Substances.
The IUR provides a “snapshot” of
chemical manufacturing every 5 years.
3
The TSCA Inventory lists
industrial or commercial chemicals
in commerce in the United States.
Currently there are over 82,000
substances on the Inventory.
4
What chemical substances are included in
the IUR?

Organic and inorganic chemicals that are:



Currently listed on the Inventory; and
Manufactured or imported at volumes of at least 25,000
pounds at a single site.
Exceptions include:





Polymers;
Microorganisms;
Naturally occurring substances;
Certain forms of natural gas; and
Substances produced as a byproduct or impurity.
5
Manufacturing Data Collected

Chemical identification information:



Chemical name
Numerical identification (i.e., CAS Registry Number)
Manufacturing information:






Production volume
Site-limited status
Manufacturing or Import activity
Number of potentially exposed workers
Physical form, w/ associated percent production volume
Maximum concentration
6
Industrial Processing and Use Data

Production Volume Threshold


300,000 pounds per year or more
Partially Exempt Chemical Categories:


Manufacturers & importers of these partially exempt
chemicals/categories report only site and manufacturing
data
Categories of chemicals include:
» Inorganic chemicals (for 2006 reporting only);
» Multi-chemical petroleum process streams (specifically
identified); and
» Specifically listed chemical substances for which there is a low
current need for IUR processing and use information.
7
Processing and Use Data Collected

Up to 10 unique combinations of:




Type of processing or use
NAICS code
Industrial function category (bleaching agent, filler,
lubricant, etc)
For each unique combination:



Percent production volume (range)
Number of sites (range)
Number of potentially exposed workers (range)
8
Consumer and Commercial Use
Data Collected


Use category (automotive care product, lawn &
garden product, soaps & detergents, etc)
For each use category:



Indication of intention for use by children
Maximum chemical concentration
Percent of production volume
9
IUR Reporting Standards

Source of information



Manufacturer of chemical substance
Importer of chemical substance
Reporting Standards



Manufacturing data is “known to or reasonably
ascertainable by”
Processing and use data is “readily obtainable”
Consumer and commercial use data is “readily
obtainable”
10
Who submits IUR data?

Sites that manufacture or import chemicals
with:



Production volume of 25,000 lbs or greater (annual,
per site) report site and manufacturing data.
Production volume of 300,000 lbs or greater (annual,
per site) report additional processing and use data.
Inorganic chemical manufacturers and
importers:


Partial exemption for the first reporting cycle and
only report site and manufacturing data.
After the first reporting cycle, required to report as
described for chemical manufacturers and importers
above.
11
Who submits IUR data?

Small businesses are exempt from
reporting

TSCA Definition of Small Businesses
» Total annual sales, including parent company,
less than $40 million and annual site production
volume less than 100,000 lbs OR
» Total annual sales, including parent company,
less than $4 million.
12
Historical Information is Available




IUR data collection began in 1986 and occurred
every four years.
IUR data was limited to organic chemicals.
IUR data was limited to chemical identity,
production volume, and site-limited status.
Non-confidential chemical records are available
under “Past IUR Data” on our website:
www.epa.gov/oppt/iur
13
How do HPV, and TRI chemicals relate to
IUR?
IUR
9,000 - 11,000 chemicals
HPV
> 2800 chemicals
TRI
> 600 chemicals
>210 HPV chemicals
14
IUR data may be used in Risk Screening:
Risk = f (Hazard, Exposure)


HPV data provides hazard information.
IUR data provides exposure related information
that may be used in combination with other
models and data to:


Determine potential screening-level occupational/public risk.
Determine potential screening-level environmental risk.
IUR
HPV
Exposure Data
Hazard Data
TRI, other OPPT tools
Risk Screening
15
Exposure Estimations Using IUR Data

Some information provided by IUR:







Information on industrial function category, NAICS code and type of
processing or use information
Production volume
Number of sites
Number of workers
Maximum concentration of chemical
Physical state of chemical
% PV used in commercial and consumer use categories

The information, along with P/C properties from HPV
Challenge Program, may be useful inputs to models (e.g.
ChemSTEER) to determine potential environmental releases
and exposures to workers

Similarly, IUR and HPV data may be useful inputs to E-FAST
model to determine potential exposures to consumers
16
Priority Setting/Occupational Risk
Screening Using IUR Data
Prioritize chemicals based on exposure related
criteria (e.g. # of potentially exposed workers)
 In combination with HPV data, could prioritize
chemicals based on both hazard and exposure
related criteria
 Flag chemicals within certain industry sectors
with high potential exposure for further follow-up
activity.

17
Priority Setting / Consumer and/or
Children Risk Screening Using IUR Data
Prioritize chemicals based on exposure related
criteria (e.g. use in consumer products, use in
products intended for children)
 In combination with HPV data, could prioritize
chemicals based on both hazard and exposure
related criteria
 Flag chemicals within certain consumer product
categories with high potential exposure for
further follow-up activity.

18
Other Potential Uses of IUR Data

Design for Environment (DfE)



Identify potential safer substitutes
IUR information on use category in combination with low
concern in hazard screen (using HPV data) could
provide list of possible safer substitutes
Occupational Safety and Health Administration
(OSHA)

Send alerts or outreach for specific chemicals based on
number of sites and number of workers likely to be
exposed.
19
Other Potential Uses of IUR Data
The IUR provides information that can be used as a
starting point for basic exposure information. Some
potential uses include:




Enabling a “first look” at a chemical, industry, or use by
providing needed information not otherwise available.
Enabling a more proactive rather than reactive approach
by providing information needed to identify trends and
upcoming issues or concerns.
Providing a starting point for more in-depth analyses and
identifying where additional information may be needed.
Placing hazard information into context, such as
information collected through the HPV Challenge Program
and similar programs.
20
2006 IUR Data Release Report


Still in the planning stages
Initial thoughts include tables such as:

National and state breakdowns
» Number of chemicals reported, total pounds
» Number of reporting facilities
» Number of manufacturers


Number of importers
Number of high volume chemicals
» Chemical name and CAS numbers
» Total production volumes




Top 100 chemicals by physical state
Chemicals used in consumer products
Chemicals used in children’s products
Worker information
» By chemical
» By number of workers potentially exposed
21
Your suggestions for other potential
uses of IUR data
22